APPENDIX B

Exide’s 2011 and 2013 Project Update Documents

Salina Project Response 10/03/2013 Exide EHS 

Date October 16, 2013 KDHE Onsite Visit Salina, KS 

Statuses of all projects completed or in process are listed below. Each project includes the date(s) 

each project is finished or anticipated completed date. All of the baghouse dates are the actual 

start up dates and stack test dates. The diverter valves and ball mill dates are the dates the CER’s 

were closed out. 

Oxide Mill #7 – Completed on 01/30/11 (stack test date 03/17/11) 

Oxide Mill #8 – Completed on 02/03/11 (stack test date 05/05/11) 

 

This capital project is designed to install two new Eagle/Linklater M1500 Oxide Reactors with 

automated controls for the oxide operations in Salina, KS. This project is phase four of five with 

the replacement of existing oxide mills 7 & 8. With the completion of phases one and two (oxide 

mills 1-4), we have seen a significant process improvement for lead in air. This is an EHScategory project required to improve our air quality in our oxide manufacturing process to help 

reduce our lead in air to the Lowest Feasible Limits (LFL). 

Oxide Mill #9 – Completed on 03/24/11 (stack test date 05/06/11) 

Oxide Mill #10 – Completed on 03/24/11 (stack test date 05/05-06/11) 

This capital project is designed to install two new Eagle/Linklater M1500 Oxide Reactors with 

automated controls for the oxide operations in Salina, KS. This project is phase five of five with 

the replacement of existing oxide mills 9 & 10. The automatic controls & mechanical upgrades on 

reactors allows uniform control of both throughput & oxide particle classification (particle size). 

With the completion of all five phases, we have seen a significant process improvement for lead 

in air. This is an EHS-category project required to improve our air quality in our oxide 

manufacturing process to help reduce our lead in air to the Lowest Feasible Limits (LFL). 

Environmental baghouse #4 – Completed on 07/04/11 (stack test date 08/10/11) 

Project Summary Listed Below 

This capital project is designed to replace our existing environmental baghouse #4 with a 120,000 

ACFM Pulse-Jet Dust Collector system to ventilate six Pasting line stackers and four Oxide Mills 

in Salina, KS. This is an EHS-category project required to maintain air quality compliance 

required by recently released "National Emissions Standards for Hazardous Air Pollutants 

(NESHAP)" standard for the Lead Acid Battery Manufacturing industry and achieve compliance 

to the NAAQS level of .15 ug/m3 effective January 1, 2010. The Salina facility contracted 

Bjerkan & Co. air ventilation engineers to determine the best baghouse configuration and 

capacity requirements to adequately support the 4 Oxide Mills & 6 pasting line stackers. They 

recommended installing a 120,000 ACFM Pulse-Jet style Dust Collector system. Installing a new 

baghouse will reduce overall lead emissions that were modeled lead emissions in an effort to 

Project Summary Listed Below for Oxide Mills 

Project Summary Listed Below 
Salina Project Response 10/03/2013 Exide EHS 

achieve compliance with the National Ambient Air Quality Standard (NAAQS) This is an EHScategory project required to maintain air quality compliance in light of the recently released 

"National Emissions Standards for Hazardous Air Pollutants (NESHAP)" standard for the Lead 

Acid Battery Manufacturing industry and achieve compliance to the NAAQS level of .15 ug/m3

effective January 1, 2010. 

Environmental baghouse #5 – Completed on 05/25/12 (stack test date 06/27/12) 

Project Summary Listed Below 

This capital project is designed to replace our existing environmental baghouse #5 with a 120,000 

ACFM Pulse-Jet Dust Collector system to ventilate the Metals, Past Mixing and 2 Assembly lines 

in Salina, KS. This is an EHS- category project required to maintain air quality compliance 

required by recently released "National Emissions Standards for Hazardous Air Pollutants 

(NESHAP)" standard for the Lead Acid Battery Manufacturing industry and achieve compliance 

to the NAAQS level of .15 ug/m3 effective January 1, 2010. 

The Salina facility contracted Bjerkan & Co. air ventilation engineers to determine the best 

Baghouse configuration and capacity requirements to adequately support the Metals, Past Mixing 

and 2 Assembly lines. They recommended installing a 120,000 ACFM Pulse-Jet style Dust 

Collector system. Installing a new baghouse will reduce overall lead emissions that were 

modeled lead emissions in an effort to achieve compliance with the National Ambient Air Quality 

Standard (NAAQS) This is an EHS-category project required to maintain air quality compliance 

in light of the recently released "National Emissions Standards for Hazardous Air Pollutants 

(NESHAP)" standard for the Lead Acid Battery Manufacturing industry and achieve compliance 

to the NAAQS level of .15 ug/m3 effective January 1, 2010. 

Relocation of oxide mill diverter valves – Completed on 07/18/12 

Project Summary Listed Below 

This project is necessary to help the Salina Facility achieve the standards set forth in the 

"National Emissions Standards for Hazardous Air Pollutants (NESHAP)" standard for the Lead 

Acid Battery Manufacturing industry, achieve compliance to the NAAQS level of .15 ug/m3 

effective January 1, 2010 and was committed to the Kansas Department of Health and 

Environment in response to an escape issue that was experienced. 

With the completion of this project the Salina Facility will have a new Oxide delivery layout with 

an auxiliary set of valves installed in a parallel system along with making the building air tight in 

the areas where the highest potential of Oxide fugitives escaping the Plant exist. This is one of 3 

projects the Salina Facility has submitted to KDHE (Kansas Department of Health and 

Environment) as corrective action in order to help us stay in compliance with NAAQS level of 

.15 ug/m3 (the projects include the Ball Mill Ventilation and Bahouse #5 Replacement projects 

which are both approved. 

Upgrade ball mill ventilation – Completed on 11/18/11 

Project Summary Listed Below for Ball-Mill 

The purpose of this Capital project is to help remove excessive heat that builds up in our Ball Mill 

manufacturing room. Currently the Ball Mill is under ventilated thus allowing the heat generated 

by the production and equipment in the mill to raise the ambient temperature to a level intolerable 

by personnel, equipment and controls. The Ball Mill room has several exterior doors that could be 

opened to allow fresh cooler air into the mill however we are not able to open them due to the 
Salina Project Response 10/03/2013 Exide EHS 

possibility of lead Oxide escaping into the atmosphere. This project will allow us to bring fresh 

air in our Ball Mill room and evacuate some of the heat without any concerns of Oxide fugitives 

escaping the room. This project will also allow us to create a safer working environment for our 

employees. 

October 03, 2013 Response 

Statuses of all projects completed or in process are listed below. Each project includes 

the date(s) each project is finished or anticipated completed date. 

 

Project Title Action Anticipated or Completed 

Date(s)

Baghouse (BH1) Replace baghouse and increase 

height to 80 feet per Salina’s 

attainment demonstrated SIP 

plan

07/01/2013 – 02/15/2014

Baghouse (BH11- BH15), ball 

mill stacks

Increase stack heights by 37 

feet demonstrated per Salina’s 

attainment demonstrated SIP 

plan

07/08/2013 – 07/19/2013 

Oxide Mill (OM1- OM10), 

oxide mill stacks

Manifold to new stack, 65 feet 

from ground level 

demonstrated per Salina’s 

attainment demonstrated SIP 

plan

07/08/2013 – 10/01/2013 

In-plant roadways Pave all internal roadways and 

parking lots subject to 

vehicular traffic on the North 

West section per Salina’s 

attainment demonstrated SIP 

plan. (Total area to be paved 

15220 SQ. Yards).

07/01/2013 – 03/31/2014

Plant process fugitive control Establish negative pressure 

building ventilation and 

maintain local exhaust 

ventilation at process points

09/21/2011 

COMPLETED

Roadways: 

Traffic on-site follows two primary routes which have been designated the Delivery Route and 

the Shipping Route. Most delivery vehicles check in at the security building at the southwest 

corner of the property and proceed clockwise around the facility to drop off or pick up their 

delivery. This route is designated Delivery Route (see Figure 2-1c). Trucks picking up batteries 

check in with security then proceed along Berg Road which is the southern boundary of the 

facility to the Eastern Distribution Center (DC) then return along a similar route along Berg 

Road. This route is designated Shipping Route in the model and is depicted on Figure 2-1d. 

Vehicular fugitive emissions were modeled as ground level adjacent volume sources. Volume 

source input parameters were calculated using the USEPA’s recommended approach in Table 

3-1 of USEPA 2004a and according to the guidance provided in the USEPA’s Haul Road 
Salina Project Response 10/03/2013 Exide EHS 

Workgroup Final Report (USEPA, 2012b). Road fugitive volume sources were calculated using a 

vehicle height of 3 meters above grade level and a vehicle width of 3 meters. Sections passing 

along Berg Road along the southern boundary of the site were modeled using a twolane approach 

with a road width of 6 meters. The model used a total of 144 volume sources on the Delivery 

Route and 82 volume sources on the Shipping Route. Delivery Route sources were 

included in source groups DELRD1, DELRD2, and volume sources on the Shipping Route were 

included in model source groups called SHPRD1, SHPRD2, SHPRD3, and SHPRD4. 

Several groups have been assigned to each route to separate two-lane from one-lane segments. 

Traffic fugitive emissions were quantified using the Paved Roads section of Chapter 13.2.1 from 

AP-42 (USEPA 2011). The equations in AP-42 require site specific data including the fleet 

average vehicle weight and a silt loading value for Paved Roads. Site-specific silt and lead 

content sampling were completed for the Salina facility in 2012. A representative sample of silt 

and lead content from an area free from off-pavement dust tracking was used for these 

parameters. 

In order to achieve attainment, it is expected that lead-in-roadway silt loading will need to 

decrease. It is further expected that paving all unpaved road sections would be an appropriate 

method of achieving the reduced silt load. The measures are aimed at reducing the silt load and 

lead content to the levels similar to the dust loading and lead content currently measured on the 

South WDC roadway (see Fig 2-1c). This area is considered representative of paved roadways 

with adequate silt control strategies in place. To capture the impact of the proposed changes, all 

roadways in this modeling exercise were modeled as paved (using AP-42 emission factors for 

Paved Roads) and assuming the silt load and the lead content of the samples collected from South 

WDC. The currently projected implementation timing for this proposed change is provided in the 

Table listed above. 

The fleet average weight and vehicle activity (path length, and number of passes / year) were 

used to estimate annual emissions of TSP, and then the percentage of particulate measured to be 

lead was used to estimate the annual lead emissions from each roadway segment. The total annual 

lead emissions were distributed evenly throughout the day, and amongst each of the volumes 

representing the line source associated with each segment of roadway. Details of the calculations 

are provided as attachment 1 in Salina’s Air Quality Dispersion Modeling Report for SIP 

Attainment Demonstration listed below. 

Air Quality Dispersion Modeling Report for SIP Attainment Demonstration 

Salina SIP 

Demonstration Full Report 20AUG13.pdf

Salina Paved Parking Map 7000-2013-PLP 

7000-2013-PLP.pdf